On 30 January 2026, the National Tax Agency released the administrative guidance (hereinafter the ‘Japanese Amended AG’, Japanese only) on the Japanese UTPR and Japanese QDMTT. These rules are equivalent to the Undertaxed Profits Rule and the Qualified Domestic Minimum Top-up Tax, respectively, under the Global Minimum Tax in Pillar 2 agreed by the OECD/G20 Inclusive Framework on BEPS and were introduced as part of the 2025 tax reform.
We have set out in this e-Tax News announcing the release of the Japanese Amended AG.
Japanese Text
KPMG Japan e-Tax News No.345
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